How did Friedrich Karl von Savigny influence conflict-of-laws theory?

Friedrich Karl von Savigny significantly influenced conflict-of-laws theory by shifting the focus away from purely territorial or mechanical rules toward a more analytical approach based on the nature of legal relationships.1

In his seminal work, System des heutigen römischen Rechts (1840–49), Savigny proposed that for any given legal problem or relationship, a jurist should identify its "seat"—the place where, according to its nature, the relationship is most appropriately governed. This concept sought to determine the applicable law by looking at the inherent connection between the legal issue and a specific jurisdiction, rather than relying solely on arbitrary territorial boundaries.21

By advocating for this method, Savigny moved conflict-of-laws theory toward a more systematic and predictable framework. His focus on the "seat" of a legal relationship provided a foundational logic that influenced how legal systems determine which jurisdiction's laws should apply, marking a departure from earlier, more rigid territorial orientations.1